§1704

1704(p)(2), 110 Stat. at 1886 (amending sec. 162(k)(2) to add sec. 162(k)(2)(A)(ii)). Under that exception, “the expense disallowance rule of section 162(k) does not apply to any ‘deduction for amounts which are properly allocable to indebtedness and amortized over the term of such indebtedness.’” Fort Howard Corp.

1704(p)(2), 110 Stat. at 1886 (amending sec. 162(k)(2) to add sec. 162(k)(2)(A)(ii)). Under that exception, “the expense disallowance rule of section 162(k) does not apply to any ‘deduction for amounts which are properly allocable to indebtedness and amortized over the term of such indebtedness.’” Fort Howard Corp.

1704(p)(2), 110 Stat. at 1886 (amending sec. 162(k)(2) to add sec. 162(k)(2)(A)(ii)). Under that exception, “the expense disallowance rule of section 162(k) does not apply to any ‘deduction for amounts which are properly allocable to indebtedness and amortized over the term of such indebtedness.’” Fort Howard Corp.

1704 (p), 110 Stat. 1886, amended sec. 162(k)(1) by striking "the redemption of its stock" and insefting "the reacquisition of its stock" effective for amounts paid or incurred after Sept. 13, 1995, in tax years ending after that date. The net effect of the amendment was simply to broaden the scope of sec. 162(k)(1) beyond the technical boundaries of "redemption". This amendment does not apply tol petitioner's redemptions, for while petitioner's 1995 fiscal year ended on Sept.

1704(p) of the Small Business Job Protection Act of 1996, Pub. L. 104-188, 110 Stat. 1755, 1868, which was signed by the President on Aug. 20, 1996, and applies retroactively to 1988, provides that the expense disallowance rule of sec. 162(k) does not apply to any "deduction for amounts which are properly allocable to indebtedness and amortized over the term of such indebtedness".

on of defending multiple claims to a limited fund or property that is under his control a procedure to settle the controversy and satisfy his obligation in a single proceeding." 7 Charles Allen Wright & Arthur R. Miller, Federal Practice & Procedure §1704 (3d ed. 2001), at 540-41 ("Wright & Miller"). Accordingly, interpleader allows a stakeholder who "admits it is liable to one of the claimants, but fears the prospect of multiple liability[,] . . . to file suit, deposit the property with the cou

on of defending multiple claims to a limited fund or property that is under his control a procedure to settle the controversy and satisfy his obligation in a single proceeding.” 7 Charles Allen Wright & Arthur R. Miller, Federal Practice & Procedure §1704 (3d ed. 2001), at 540-41 (“Wright & Miller”). Accordingly, inter-pleader allows a stakeholder who “admits it is liable to one of the claimants, but fears the prospect of multiple liabilityt,] ... to file suit, deposit the property with the cour